COMMISSIONER OF INCOME TAX (IT & TP) vs. M/S. DONGFANG ELECTRIC CORPORATION
ITAT/66/2018HC Calcutta09 Jul 2021
Bench: : The Hon’Ble Justice Surya Prakash Kesarwani
Section 132(1)Section 132(4)Section 133ASection 139Section 153ASection 271(1)(c)Section 274
reassessment shall be deemed to constitute
satisfaction of the Assessing Officer for initiation of the penalty
proceedings under the said clause (c).
274. Procedure.- (1) No order imposing a penalty under this
Chapter shall be made unless the assessee has been heard, or has
been given a reasonable opportunity of being heard.
(2) No order imposing a penalty under this